Simplebooklet Privacy Policy

Last updated: January 2, 2024

Welcome to Simplebooklet. This Privacy Policy applies to Simplebooklet services (the “Platform”), which include Simplebooklet apps, websites, software and related services accessed via any platform or device that link to this Privacy Policy. The Platform is provided and controlled by Simplebooklet Inc., with its registered address at 6449 Douglas Street, West Vancouver, BC, Canada, V7W2G3 (“Simplebooklet”, “we” or “us”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users, and other individuals in connection with our Platform. If you do not agree with this policy, you should not use the Platform.

What information we collect

We may collect the following information about you:

Information You Provide

Your profile information. You give us information when you register on the Platform, including your username, password, email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video.
User content. We process the content you generate on the Platform, including photographs, audios and videos you upload or create, comments, hashtags, feedback, forms, and the associated metadata, such as when, where, and by whom the content was created (“User Content”). Even if you are not a user, information about you may appear in User Content created or published by users on the Platform. We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.
Messages. We collect information you provide when you compose, send, or receive messages through the Platform’s messaging functionalities. They include messages you send or receive through our comments functionality when communicating with and between users. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.
We may access content, including text, images, and video, found in your device’s clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform, or choose to paste content from the clipboard into the Platform, we access this information stored in your clipboard in order to fulfill your request.
Purchase information. When you make a purchase or payment on or through the Platform, including when you buy Simplebooklet services or purchase goods through our shopping features, we do not collect information about the purchase or payment transaction, such as payment card information or billing. We do collect information about delivery, and contact information, and services you purchased.
Proof of your identity or age. We sometimes ask you to provide proof of identity or age in order to use certain features, such as verified accounts, ensure that you are old enough to use the Platform, or in other instances where verification may be required.
Information in correspondence you send to us, including when you contact us for support or feedback.
Information through surveys, research, promotion, contests, marketing campaigns, challenges, competitions or events conducted or sponsored by us, in which you participate.

Automatically Collected Information

Usage Information. We collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, videos you watch and problems encountered, browsing and search history, the content you like, the content you save to ‘Following’, the users you follow and how you engage with mutual followers.
Technical Information we collect about you. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, time zone settings, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.
Location Information. We collect information about your approximate location, including location information based on your SIM card and/or IP address.
Cookies. We and our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, and measure the effectiveness of the platform. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. To learn how to disable certain Cookies, see the “Your rights and choices” section below.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

If you choose to register or use the Platform using a third-party social network account details (e.g., Facebook, Twitter, Instagram, Google) or login service, you will provide us or allow to provide us with your username, public profile, and other possible information related to such account. We will likewise share certain information with your social network such as your app ID, access token and the referring URL. If you link your Simplebooklet account to another service, we may receive information about your use of that service.
We may obtain information about you from certain affiliated entities, including about your activities on their platforms.
We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

How we use your information

As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, personalize content you see on the Platform, promote the Platform, and customize your experience. We generally use the information we collect in the following ways:

To fulfill requests for services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
To personalise the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen.
To send promotional materials, including by instant messaging or email.
To improve and develop our Platform and conduct product development.
To measure and understand the effectiveness of the features and other content we serve to you and others on the Platform.
To support the social functions of the Platform, including to permit you and others to connect with each other (for example, through our Follower and Comments function) and to share whether you are active on the Platform (and other information which you choose to share), to provide our comments service if you choose to use this function, and for you and others to share, download, and otherwise interact with User Content posted through the Platform.
To understand how you use the Platform, including across your devices.
To infer additional information about you, such as your age range, gender, and interests.
To help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform.
To ensure content is presented in the most effective manner for you and your device.
To promote the safety, security of the Platform, including by scanning, analyzing, and reviewing User Content, messages and associated metadata for violations of our Terms of Service, Community Guidelines, or other conditions and policies.
To verify your identity or age.
To communicate with you, including to notify you about changes in our services.
To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.
To enforce our Terms of Service, Community Guidelines, and other conditions and policies.
Consistent with your permissions, to provide you with location-based services.
To train and improve our technology, such as our machine learning models and algorithms.
To facilitate and fulfill sales, promotion, and purchases of goods and services and to provide user support.

How we share your information

We share your information with the following parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google, Microsoft), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

Where you opt to share content on social media platforms, the video, image, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.

Payment processors and transaction fulfillment providers: If you choose to subscribe or conduct other payment related transactions, we will share data with the relevant payment provider to facilitate this transaction.
Analytics providers: We use analytics providers to help us in the optimisation and improvement of the Platform, and provide reporting on activity surrounding the shared content distributed on the Platform.

For Legal Reasons

We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if such use is reasonably necessary to:

comply with legal obligation, process or request;
enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Public Profiles

Please note that if your profile and content is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a your content each time you upload a file. Alternatively, you can change your content to link only and paused from the “SHARE” settings for each content you manage in the Platform.

Sale, Merger or Other Business Transactions

We may also disclose your information to third parties:

in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Merchants, Payment and Transaction Fulfillment Providers, and Other Service Providers

When you make a purchase, we share the information related to the transaction with the merchant, payment and transaction fulfillment providers, and other service providers. For example, we will share the order items, contact details and delivery information so your order can be processed. These entities may use the information shared in accordance with their privacy policies.

Where we store your information

Your information may be stored on servers located outside the country where you live, such as in Ireland and the United States. We maintain major servers around the world to bring you our services globally and continuously.

Your rights and choices

You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may submit a request to exercise your rights under applicable laws at support@simplebooklet.com. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. Please also see the Supplemental Terms below on whether a local representative or local contact is available for your country.

You can access and edit most of your profile information by signing into Simplebooklet. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your content, send you messages, or post comments to your content. Should you choose to do so, you may delete your entire account.

You may be able to refuse or disable Cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

The security of your information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

How long we keep your information

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile and User Content from public view immediately, but may keep other information about you to process the violation.

Information relating to children and teens

Simplebooklet is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements, please see your local supplemental terms for more information. If you believe that there is a user who is below this minimum age, please contact us at support@simplebooklet.com.

Privacy Policy update

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

Contact

If you have questions, comments, complaints or requests regarding this Privacy Policy, please contact us at: support@simplebooklet.com

We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant data protection authority, where applicable.

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Argentina

If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Your rights and options

According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to support@simplebooklet.com free of charge.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos.

Brazil

If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. confirmation of whether your data are being processed;

II. access to your data;

III. correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. object to the processing of personal data;

VII. information of public and private entities with which we shared data;

VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. withdrawal of your consent.

X. request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.

DPO: If you wish to reach the Simplebooklet’s Data Protection Officer, contact us at: support@simplebooklet.com

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment for at least 6 months, in order to comply with legal obligations.

Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.

International Transfers. International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

Canada

If you are using the Platform in Canada, the following additional terms apply.

Information Relating to Children and Teens. Please note that if you are a resident of the Province of Quebec, you are only permitted to use the Platform if you are at least 14 years old.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request or that they are authorized to act on behalf of another individual in such matters.

Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send.

Internal Policies and Access Controls. We implement and maintain internal policies and technical measures to restrict access to your personal information within our organization. Access to personal information within our organization is limited to employees who need the information to perform their job functions. For example, our customer support team may have access to certain types of information during our interactions with you, such as responding to complaints and inquiries. Similarly, our content moderators may access certain information in order to enforce our Terms of Service, Community Guidelines, and other conditions and policies.

Data Retention Practices. We have procedures in place to limit the retention periods as set out in the “How Long We Keep Your Information” section above. When personal information is no longer needed for these purposes or is no longer required to be retained by law, we take appropriate steps to dispose of it securely in accordance with our internal procedures.

Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States, Malaysia, Ireland, Singapore, and other foreign jurisdictions where we or our service providers are located. For information about how we or our service providers (including service providers outside Canada) process personal information, please contact us using the contact information set out below. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.

Contact. If you are a resident of Canada, you can contact our Privacy Office at support@simplebooklet.com

Egypt

If you are using our services in Egypt, the following additional terms apply.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged Simplebooklet's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

Indonesia

If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall apply.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

Your Choices. You may withdraw your consent to Simplebooklet's disclosure of personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of Simplebooklet features and functionality.

You may request Simplebooklet to (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of Simplebooklet’s features and functionality.

To exercise any of your rights, contact us at: support@simplebooklet.com

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Israel

If you are using our services in Israel, the following additional terms apply.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged Simplebooklet's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

Other Jurisdictions

In jurisdictions where the national or official language is not English, the version of the Simplebooklet Privacy Policy in your local language may set out additional terms specific to your jurisdiction. Please also refer to the version of this Privacy Policy in your local language for further information.